Scottish Government Energy Performance Certificate Reform Consultation

The ASSC welcomed the opportunity, today, to respond to the Scottish Government’s consultation on Energy Performance Certificate Reform.

The issue of Energy Performance Certificates (EPCs) is a policy area where we have engaged with Scottish Ministers and officials over several years. We intend to continue this dialogue in the best interests of the self-catering industry in Scotland in the hope the regulatory burden can be minimised.

To help inform our submission to this consultation, the ASSC undertook a survey of its membership in October 2023 to gauge the views of small businesses operating in the self-catering and short-term let sector regarding EPCs.[1] This highlighted the following relevant points:

• 62% of respondents have properties which are EPC D or below;
• The overwhelming majority (92%) of self-caterers do not currently charge guests at their property for electricity costs;
• Half (50%) received an EPC as part of their short-term let licensing application, while 38% already had one;
• Nearly two-in-ten (19%) of operators experienced issues when attempting to obtain an EPC. This included a shortage in the availability of EPC consultants and assessors across many areas;
• 96% oppose the proposal to reduce the validity period of EPCs from ten to five years;
• Only half were aware that the Scottish Government’s consultation proposed introducing a minimum standard of EPC rating. Just 5% would support this approach; and
• 92% were either ‘very’ or ‘somewhat’ concerned about their business if required to reach a higher EPC standard under any new legislation.

The Heat in Buildings Strategy confirmed the Scottish Government’s intention to require Scotland’s homes to meet EPC Band C equivalent, where that was “technically feasible and cost effective” from 2025 onwards, with some backstop dates from 2028 to 2033. If this requirement captures self-catering properties, which are primarily used for tourist accommodation, this would cause considerable difficulties for our sector in what are already challenging times.

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